In Spain, e-invoicing with the public sector has been mandatory since 2015 through FACe (the government’s invoice portal). For business-to-business (B2B), it will become mandatory in stages once the detailed regulation is officially published under the “Crea y Crece” law. This guide explains what an electronic invoice is, when B2B becomes mandatory, how it differs from Verifactu (the anti-fraud rules for billing software), and what to do now if you sell to the public sector or to other businesses.
Quick Q&A
What is an electronic invoice in one line?
A tax invoice in digital form that stays readable, proves who sent it, and shows it hasn’t been changed.
Where is it already mandatory?
B2G (business to government) has required e-invoicing since January 2015 via FACe.
When will it be mandatory for B2B?
After the B2B regulation is published. Companies above 8 million euros in turnover will have 1 year to comply. Everyone else will have 2 years.
Is Verifactu the same thing?
No. Electronic invoicing defines the document and the network used to send/receive it. Verifactu is a separate rule set for billing software that blocks hidden edits and parallel records. Here’s the difference explained.
Do I need a special format today?
For B2G, yes: Facturae 3.2.1/3.2.2 (Facturae is Spain’s XML file format for public-sector e-invoices). For B2B, formats and exchange rails will be set in the final regulation.
What should I do now?
Pick software that can issue, receive, acknowledge, and store e-invoices, supports FACe/FACeB2B, and is ready for Verifactu.
Electronic invoice: quick definition and where Spain stands
Simple definition.
An electronic invoice is just a normal tax invoice in a digital file. It must be readable, show who sent it, and prove no one altered it after issuing.
Where Spain stands today.
- B2G: mandatory since 15 January 2015. Suppliers send Facturae through FACe.
- B2B: not active yet. The clock starts on the day the regulation is published: 1 year for companies with turnover over 8 million euros, 2 years for the rest.
What is an electronic invoice?
Core elements.
It has the same fields as paper: number and series, issuer and customer details and tax ID, dates, concept, taxable base, VAT, and totals. The change is how you send, receive, confirm, and store it.
Three legal qualities you must guarantee.
- Legibility: a person can read it with common software.
- Authenticity of origin: it really comes from the sender.
- Integrity of content: it hasn’t been changed after issue.
How to guarantee them.
Use a qualified electronic signature (a certified digital ID), EDI (a standard way companies exchange documents), or strong internal controls that leave an audit trail. The B2B rule will also define the exchange method, acknowledgement messages, and - if confirmed - how to report payment status.
Formats and rails in Spain today
B2G.
Use Facturae 3.2.1/3.2.2. You can create it with the desktop tool or MiFacturae (the public web app) and send it through FACe. You can then track status in the portal or through an integration.
B2B.
The regulation will set the formats, how systems talk to each other, and status reporting. Expect a public rail plus private platforms that must interconnect. Your software will need to connect (directly or via a gateway), exchange messages both ways, and handle acknowledgements without manual work.
Names you will keep seeing.
- FACe: public portal to submit e-invoices to public bodies.
- FACeB2B: a routing network for B2B e-invoices.
- MiFacturae: public web app to create and send e-invoices to the public sector.
Mandatory electronic invoice
Already mandatory.
If you invoice a public administration, you must use Facturae and send it through FACe. Paper or simple PDF is not valid there.
B2B will become mandatory under Crea y Crece.
All B2B invoices must be issued, sent, and received as e-invoices after the regulation is published. Timeline from that date:
- Turnover above 8 million euros: 1 year to comply.
- Everyone else: 2 years to comply.
2025 snapshot.
The government ran a second public hearing in 2025. Final approval is pending. Plan for roll-outs during 2026-2027 depending on publication. Assume your 1- or 2-year clock starts the day it’s in the official journal.
Penalties (high-level).
Drafts mention fines if a business doesn’t allow e-invoice reception or access to past invoices for former customers. Treat numbers as context until the final text is out.
Practical take.
Even before the final text, align with what’s stable today: Facturae/FACe for B2G and connectivity to FACeB2B. Remember: Verifactu (Spain’s anti-fraud software rules that add a QR code and secure records) is separate and starts in 2026 for software users.
Crea y Crece Law: why it makes e-invoicing compulsory
Legal basis.
Law 18/2022 extends e-invoices to all B2B deals to cut late payments, improve traceability, and push digital tools.
Implementation logic.
Phased by turnover once the regulation is published: big firms first, then SMEs and self-employed a year later.
Payment status reporting.
Drafts in 2025 included that recipients report invoice status and, in many cases, the effective payment and date. This links e-invoicing to late-payment control.
How rails will coexist.
Facturae stays for B2G. For B2B, the rule will set how the public solution and private platforms connect. Your tool should issue, receive, acknowledge, report statuses (if confirmed), and archive - all in one place.
What SMEs and self-employed should do now
- Choose software that issues and receives e-invoices, validates them, and stores them for the legal period.
- If you bill the public sector, confirm Facturae, FACe, and FACeB2B support now.
- Ask vendors for a clear roadmap on B2B formats, acknowledgements, public-solution interconnection, and payment-status reporting.
- Run a small pilot with one real client and one test client: issue → send → receive → acknowledge → correct → pay → archive.
- Define roles: who issues, who approves, who checks payment. Avoid side PDFs and email threads.
Billing news 2025
Regulatory process.
- Second public hearing: March-May 2025. The government gathers comments and refines formats, message flows, acknowledgements, and - possibly - payment-status scope and timing.
- Your countdown starts only when the final text is published in the official journal.
What to monitor next.
- Final list of accepted B2B file formats and envelopes.
- Interconnection rules between private platforms and the public solution.
- Status dictionary (issued, received, accepted, rejected, paid, etc.) and which ones are mandatory to report.
- Any grace periods or progressive enforcement for micro-issuers.
What won’t change.
- B2G remains Facturae over FACe.
- Verifactu runs in parallel and is separate from B2B e-invoicing.
What may change.
- Exact cadence and payloads for reporting acceptance and payment.
- Extra public tools for very small issuers.
Action for 2025.
Treat 2025 as your prep year: enable structured exchange now (Facturae where relevant, connectors for interoperability). Pilot with your main customers and suppliers so you are ready when the rule lands.
From how much is it mandatory to issue an invoice?
General rule.
If you are a business or a professional, you must issue an invoice for all your operations. This comes from Spain’s Billing Regulation.
Simplified invoices and thresholds.
- You may issue a simplified invoice for totals up to 400 euros (VAT included), or for rectifying invoices.
- You may use a simplified invoice up to 3,000 euros (VAT included) only in certain activities such as retail to consumers, passenger transport, and hospitality (as listed in the rule).
When to avoid simplified invoices.
Between businesses, the recipient usually needs a full invoice to deduct VAT. If your activity is not on the list that allows simplified invoices up to 3,000 euros, issue a full invoice even for small amounts.
Edge cases.
- Advance payments and deposits: issue an invoice when you receive the advance and reconcile it on the final invoice.
- Continuous services: define a period (for example, monthly) and invoice at period-end or per milestone.
- Reverse charge: still issue an invoice and show the correct VAT notes and legal articles.
- Intra-EU supplies: the core data stays the same, but make sure the customer VAT ID and supply rules are correct.
How to create, sign, and send an electronic invoice
B2G today
- Create the file in Facturae 3.2.1/3.2.2 (desktop tool or MiFacturae).
- Sign it with a qualified certificate - the app usually handles the signature for you.
- Send it through FACe - you’ll get a registration number and status updates.
- Track statuses (received, registered, accepted, paid) and archive the file plus metadata.
B2B once the regulation is published
- Issue and receive structured e-invoices and validate both outgoing and incoming files.
- Send and receive acknowledgements automatically (receipt and acceptance/rejection).
- Be ready to report statuses like acceptance/rejection and payment/date if the final text requires it.
- Interoperate with the public rail and private platforms through certified connectors.
- Archive the invoice, its signature, the acknowledgements, and the status trail for the full legal term.
Acceptance and rejection in practice.
- Receipt confirms the file reached your counterparty.
- Acceptance/Rejection comes after their checks (for example, PO match or tax ID check). Rejections should include clear machine-readable reasons so you can fix and resend.
- Payment status (if required): when and how much was paid, tied to the invoice ID.
Archiving that passes an audit.
- Keep the original structured file, the signature, timestamps, all acknowledgements, and the status history.
- Make everything searchable by customer, date, amount, and series.
- If you switch systems, export all data and logs in bulk.
Practical checklist for SMEs and self-employed
- Map your scenarios: who you bill (public bodies, companies, or both).Demand core capabilities from your software:
- B2G: create Facturae and submit through FACe.
- B2B: issue, receive, validate, acknowledge, and (if confirmed) report statuses.
- Archive: legal storage with search and bulk export.
- Verifactu-ready: compliant anti-fraud features from 2026.
Common mistakes to avoid
- Staying on PDFs for B2B - a plain PDF by email won’t meet the rules.
- Ignoring reception and validation of inbound e-invoices.
- Not archiving metadata (signatures, statuses, logs) along with the invoice file.
- Skipping small live pilots before the rule goes live.
Bottom line
B2B e-invoicing will be required under Crea y Crece. Prepare now: choose a tool that already works with Facturae and FACe for B2G, is ready to interconnect for B2B, and meets Verifactu from 2026. When the regulation is published, your 1- or 2-year countdown begins. Plan early so e-invoicing feels like a smooth upgrade, not a last-minute scramb
